American Seating Company, John Adelsperger
June 8, 2007  [via Email]

We appreciate having the opportunity to respond to this draft in advance of the rule making and being able to attend the open meetings on the subject in the past.  We believe there are several areas of the current ADA regulations that should be addressed and we were pleased to find that some of those were in your draft.  I have listed below our comments to the specific paragraph.  A general comment that I would make is that the industry needs specific performance requirements, not generic statements that are in the previous document and in this document in a few instances.  Examples would be slip resistant or emergency driving conditions.  There are ISO or RESNA standards that are either final or in process that have been developed by knowledgeable people in the industry that could be used.  If there are no test methods stated, the performance requirement should be removed.

• Subpart A, 1192.3 Definitions.  We believe that leaving out a definition of a “common wheelchair” is not a significant  issue as it is somewhat defined by other sections of the guideline such as: 1192.2 ( c ) and 1192.23 (d) (2) for 30" x 48" and 1192.3 (b) (1) for weight of 660 pounds.  We do believe it would be better to provide a definition of a wheelchair and mobility aid as informational, not regulatory.
• Subpart B, 1192.23, paragraph (d) (1).  Securement design loads should be reviewed and made more clear.  The current requirement for large bus is 2000 lbs per securement leg in the forward direction and a minimum of 4000 pounds for each mobility aid.  This represents about a 6g loading based on a 660 pound combined weight of the occupant and the mobility device.  Many research studies by the industry have shown that under emergency driving conditions, the maximum forward force from maximum braking does not exceed .85g.  Side loading from emergency maneuvers don’t exceed .5g.  Frontal impacts with an automobile with a 30 mph differential is approximately 3 g.  All of this information is readily available for review.  This would suggest that the strength requirements could be reduced to a maximum of 1,000 pounds per rear securement leg for forward facing restraint systems in large bus experiencing a 3g deceleration.
  
  This standard has been interpreted in the past as requiring the front belts of a 4 belt securement system to meet 2000 pounds per securement for large bus.  The front securement of a forward facing securement system will only see the rebound load from a front impact and a minimal load for a bus being hit in the rear.  American Seating would like for the ADA guidelines to be clearer about the 2000 pounds per securement leg to only being applicable to the rear securement legs in a forward facing application for large bus.
• Subpart B, 1192.23, paragraph (d) (2).  The new guideline has eliminated the ability to count space under a seat as part of the clear floor area.  We agree that it is seldom used, but there are instances where using this space can be helpful in maneuvering, especially now that the required space is larger and will be hard to meet in certain bus layouts. We would like to see this left in the guideline.
• Subpart B, 1192.23, paragraph (d) (2)I and  ii.  These two sections are new.  They define wheelchair space that is a forward approach and a parallel approach.  Large bus only uses the parallel approach.  For a parallel approach, where there is protrusion from the side wall like a wheelhouse, barrier or transverse flip up seat that exceeds 15 inches, the length will be required to be 60 inches.  This will result in the loss of seated passengers and there may be a number of shorter heavy duty transit buses where the restraint area may not accommodate 60 inches in length on the RH side.  They may also not be capable of doing in line on the left side of the bus.  American Seating would recommend that the requirement be revised to having one of the restraint locations to be  30 inches by 48 inches and the second location would be required to be  30 inches by 60 inches.  This would be a compromise that would improve the ability to use, not create as significant of an issue with the bus builders and not lose as many seated passenger positions.  It is also a strategy that we have already seen in the industry.
  
  We find the figures shown in this section confusing.  I think it would be helpful to add arrows showing where the front of the bus is.  Description of size needs to be revised to describe the 60 inches from wide to long.  We believe the increase in length is a positive, although difficult, change for the industry and its users.
  
  There are some in the industry that believe there should be a limit placed on the stored width of the longitudinal flip up seats of 5 inches.  That could be helpful in providing adequate space, but it would be very limiting for the bus operator in choosing the styling and comfort of their seats.  There are very few seats available in the industry that would meet this requirement.  We would not recommend incorporating a 5 inch maximum seat thickness.
• Subpart B, 1192.23, paragraph (d) (3).  Mobility aids accommodated has been revised to: “The securement system shall secure wheelchairs and mobility aids which can enter and maneuver within a vehicle complying with this subpart and shall either be automatic or easily attached by a person familiar with the system and mobility aid and having average dexterity.”  We believe this is confusing.  If the space provided isn’t required to exceed 30 inches by 48 inches, which is the minimum by this guideline, why are the mobility devices not limited specifically to that size as a maximum.  If this isn’t done, then you can have mobility devices that could maneuver in some buses and not in others.
  
  This would be a good section for reference to be made to RESNA-WC-19 compliant wheelchairs.  There needs to be some emphasis made in this document that there is a standard established for a mass transit transportable wheelchair that provides a wheelchair that is easily secured.
• Subpart B, 1192.23, paragraph (d) (4).  The definition for the rear facing barrier is not sufficient to describe a barrier where the barrier would actually provide support for the mobility aid user.  The padded barrier needs to not have any obstructions immediately beneath the pad to be functional.  I would suggest that the Access Board look at what has been developed for and shown in the working draft of  ISO/TC 173/SC 1 N 494.  For BRT applications, what is proposed in this document is not adequate.  It still requires the use of belts as we read it.  BRT’s require that stops be made in a shorter time frame than other transit buses.  We would suggest that you look at compartmentalism in order to speed up the loading process for BRT’s.  There is a significant amount of research that has been done in Canada and Europe that would support compartmentalism.
• Subpart B, 1192.23, paragraph (d) (5).  Normal operating conditions needs to have specific performance requirements,  otherwise, the industry will not be consistent.  I believe this is as important as defining the load requirements that are clearly stated in Subpart B, 1192.23, paragraph (d) (1).  There have been various industry groups that have investigated this requirement.  It is referenced in the ISO standard noted above that emergency braking and evasive maneuvering produces loads on an occupied mobility devices in the range of 0.3 to 0.85g.  Additionally, there needs to be a definition added to determine what device  is used to evaluate the 2 inch maximum movement. We would recommend that reference be made to ISO/TC 173/SC 1 N 494 Annex  D that defines a surrogate wheelchair.  With this device, an indicator can be applied at the center of the device to measure maximum movement consistently.  There has to be a standardized method for evaluating this requirement.  The industry can not be held responsible for maximum movement of every conceivable mobility device.
• Subpart B, 1192.23, paragraph (d) (6) Stowage.  We don’t interpret that this has made any significant change, however, we would recommend this section to be reworded for better clarity as follows: When the securement system is not in use, it shall not protrude into the clear floor space as defined by this guideline,  extend beyond the cushion of the flip up seat when it is in its down position, interfere with passenger movement, shall not present a hazardous condition, shall be reasonably protected against vandalism and shall be readily accessed when needed for use.  When we design a securement layout, we do not permit the securement devices to intrude into the clear floor space.  If there is an intended impact not clearly noted, we would like to have it spelled out.
• 1192.29 paragraph C.  This paragraph indicates that handholds shall be provided adjacent to the aisle of each forward or rear facing seat.  In the case of a back to back seat that may be used, it is only a need to have the handhold on one of the seats, not both.
• General comments:
  • We have not specifically commented on the increase in aisle width for circulation of mobility devices, ramps, etc.  Each bus manufacturer has different design constraints which they should evaluate and comment on.  We provided all of our major transit bus builders with this draft document and recommended that they comment.
  • Regarding whether the SAE standards are better than 49 CFR 571, we are not certain which SAE standard that you might be referencing.  We currently use SAE J2249 (soon to be RESNA-WC-18) as a guideline for our internal standards.  There are bus layouts and/or bus structural designs where this standard can not be met..

John Adelsperger [email]
Director of Engineering
American Seating Company
401 American Seating Center
Grand Rapids, MI  49504